Questione giuridica chiave
Whether the federal appeal raised a question of fundamental importance justifying ordinary civil appeal jurisdiction.
Decisione estratta
No such fundamental legal question was shown; existing case law already clearly answers the prescription question in definitive debt-enforcement proceedings.
Motivazione estratta
Prescription may be invoked only if it arose after the title became final, and the debtor must expressly raise it; the appellant relied on inapposite public-law tax case law and failed to demonstrate a fundamental issue.